The OIG has issued their Semiannual Report to Congress for the period April 1, 2021 through September 30, 2021. The report highlights nearly $4 billion in expected investigative and audit recoveries identified during FY 2021. The report details the OIG’s ongoing work through investigations and enforcement actions which include:

• $787 million in recoveries from audits
• $3 billion in expected investigative recoveries
• 532 criminal actions
• 689 civil actions
• 1,689 excluded individuals

The types of issues identified that contributed to the nearly $4 billion in expected recoveries include:

• COVID testing related schemes
• Billing inpatient claims that did not meet Medicare criteria for inpatient status and should have been billed as outpatient/observation
• DRG upcoding
• Improper risk adjustment coding
• Improper billing of the following types of services:
  • Inpatient rehabilitation
  • Chronic care and transitional care management services
  • ESRD
  • Home health
  • Hospice
• Prescribing medically unnecessary items
• Performance of unnecessary laboratory tests including cholesterol testing 

We recommend reviewing the Semiannual Report in its entirety to identify risks that are pertinent to your organization.  Identified areas of risk should be evaluated as part of your compliance program’s auditing and monitoring efforts.

The Semiannual report can be found here:  https://oig.hhs.gov/reports-and-publications/semiannual/index.asp
 
HBE’s team of experts is available to assist you with risk assessments, routine auditing and monitoring, policy and procedure development as well as customized education and training for your clinical and administrative staff.

DISCLAIMER:  This newsletter contains only summary information and highlights; it should be read in conjunction with the full article or document provided as a link.  Any advice or recommendations are general and specific questions should be directed to professional counsel.